Privacy Policy
by Bingo-Soft LLC
Last Revised: June 01, 2023

Privacy Policy describes the information We collect from You, how We use that information, and
our legal basis for doing so. It also covers whether and how that information may be shared, and Your
rights and choices regarding the information You provide to Us.

Who We are?
We are Bingo-Soft LLC (“We”, “Us”, “our”). We are registered in Russia under company number
1115259010184 (TIN: 5259097373), and We are located in 282, 23, Krasnye Zor Street, Nizhny Novgorod city, Nizhny Novgorod Region, 603157.
We are the owners (right-holders) of the STERY low-code platform. We are among the first to
develop a low-code platform as a massive business solution. We have been delivering custom low-codedevelopment IT services since 2011.

About Privacy policy
This document and Bingo-Soft LLC processes have been made in accordance with (1) the Federal
Law "On Personal Data" dated July 27, 2006, № 152-FZ discloses: the obligations of the right holder, who is a Processor and a Controller, the methods and basis of processing personal data, as well as the rights of subjects of personal data from the Russian Federation; (2) the requirements of the legislation (e.g. GDPR,CCPA, LGPD) on personal data discloses: the obligations of the right holder, methods and grounds of processing, personal data protection measures, as well as the rights of personal data subjects who are citizens of foreign countries.
This legal document is public and available at http://stery.pro/privacy
This Privacy Policy governs our Website (http://stery.pro) and software that link to, or contains
references to this document and is published or made available by Us.
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of
Your information when You use the Service and tells You about Your privacy rights and how the law
protects You.
We use Your Personal data to provide and improve the Products. By using the Website and the
Product, You agree to the collection and use of information in accordance with this Privacy Policy.

PLEASE READ THIS PRIVACY POLICY CAREFULLY
It summarizes the various ways We acquire and treat Your Data when You access, visit and/or use
our software. This Privacy Policy does not cover information collected on sites, applications, destinations, or services linked from our website and software that We do not own or control.

Please note We will update this Privacy Policy from time to time to reflect any changes or
proposed changes to our use of Your personal data, or to comply with changes in applicable law or
regulatory requirements. We may notify You by email of any significant changes to this Privacy Policy,
but We encourage You to review this document periodically to keep up the date pf the last revision.
YOU ACKNOWLEDGE THAT YOU HAVE FULLY READ, UNDERSTAND, ACCEPT AND AGREE WITH OUR
PRIVACY POLICY AND OTHER LEGAL DOCUMENTS without the exceptions and qualifications, so You are
responsible for their violation.
THE CONDITIONS OF THIS PRIVACY POLICY, AND OTHER LEGAL INSTRUMENTS ALLOWED IN THE
TERMS AND CONDITIONS ARE SIGNIFICANT FOR YOUR EXECUTION.
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If You do not agree with all of our Privacy Policy or a part of it, then please don't use our Services!
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Glossary
The text of our Privacy Policy uses terms and concepts with the following meaning:
Personally Identifiable Information (referred to in this document as “PII”) means that alone or in
combination with other information or certain contexts can be used to identify, distinguish or trace You
and Your Device(s);
Data means all information that We or Third parties have got from You, including technical
information about Your Device(s) or accounts and non-personal identification information;
Product means the STERY low-code platform, that was developed, published or made available by
Us;
Third party (or Third-Party Providers) means the third party with whom We entered into an
agreement and / or collecting, processing and storing Your technical, and other data;
Device means a hardware operated by a person and may refer to a smartphone, tablet;
Website refers to STERY, accessible from http://stery.pro/
Cookies mean small files that are placed on Your computer, mobile device or any other device by a
website, containing the details of Your browsing history on that website among its many uses;
Profile and / or Account means the section of the Product that contains details, data and (or) other
information about a User. By using an Account, You may access to using the Product.
User means You as the person who had created an Account and use the Product.
All the above terms can be indicated in the plural. When using the term, it is necessary to start from
the context of the text of using the term. All capitalized terms used in this Privacy Policy that are not
otherwise defined have the meanings set forth in the Glossary.

1. Introduction
This Privacy Policy governs websites, software that link to, or contain references to, this document
and are published or made available by Bingo-Soft LLC, its parent, subsidiaries, and affiliates. Please read this Privacy Policy carefully. It summarizes the various ways We acquire and treat Your Data when Youaccess, visit and/or use the Product.
You can access this Privacy Policy any time on the Product's description screen, or as otherwise
indicated depending on the Product You are using, or at http://stery.pro/privacy
By visiting the Website or by clicking the button with the text “I Agree” and using the Product: You
agree to be bound by this Privacy Policy at http://stery.pro/privacy
If You don’t agree with the terms and conditions of this Privacy Policy, You should not access, visit
and/or use the Product. We advise that You print or retain a digital copy of this Privacy Policy for futurereference.
This Privacy Policy may be modified from time to time, so check back often. So that You are aware
changes have been made, We will adjust the “Last Revised” date at the beginning of this document. If Wemake a significant change in the way We use or share Your PII, We will also post on the Product a
prominent notice that a change was made. Continued access to the Product by You will constitute Youracceptance of any changes or revisions to the Privacy Policy.
This Privacy Policy in the part of Personally Identifiable Information must be used only in a case,
when You give to Us (or to Third-Party that provided by Us) Your PII such as Your name, email address,
postal address, or phone number, not all Your Data.

2. The Types of Data Acquired About You

2.1. Data
Information Maintained on Your Device. When You visit the Website or use the Product(s), and
when You have enabled such collection in Your device or Product’s(s’) settings, We may collect certain information maintained on Your Device to help Us tailor our Product(s) to You.
2.2. Children’s Privacy Data
Protecting the privacy of Young children is especially important. Our Products are not directed to
children under the age of 18, and We do not knowingly collect PII from children under the age of 18
without obtaining parental consent. If You are under 18 years of age, then please do not use or access the Product at any time or in any manner. If We learn that PII has been collected on the Product from persons under 18 years of age and without verifiable parental consent, then We will take the appropriate steps to delete this information.
The Product is not intended to be used by children under the age of 18 and is not intended to be
used to post content to share publicly or with friends. To the extent that children under the age of 18 have posted such content on the Product, children under the age of 18 have the right to have this content deleted or removed using the deletion or removal options detailed in this Privacy Policy. If You have any questions regarding this topic, please contact Us as indicated in Section 10. Please be aware that, although
We offer this deletion capability, the removal of content may not ensure complete or comprehensive
removal of that content or information.
2.3. Anonymous Data
Some of the Data that We acquire cannot identify, distinguish or trace You or Your Device, even if
combined with other identifying information, and some Data that could be considered PII when combinedwith other identifying information is not used in a way that identifies, distinguishes or traces You or Your
Device, but is instead used anonymously, often aggregated with other anonymous Data about other users.
2.4. Credit/Debit Card and Payment Account Data
We will not ask, and get, and sell or rent Your credit/debit card number or payment account Data.
2.5. PII
We may ask You to provide Us with certain Personally Identifiable Information that can be used to
contact or identify You. PII may include, but is not limited to:
• Email address
• First name and last name
• Phone number
• Usage Data
3. How We Acquire Your Data
3.1. Data You Provide
We mostly receive Your Data and PII because You provide Data and PII by the Product to Us, the
Third Party by Your deliberate choice.
3.2. Data Automatically Collected
The Product may also automatically collect Data about You, Your online behavior, and Your Device.
The Data collected may include, without limitation:

Unique device identifier generated from the device MAC/IMEI/MEID, which We alter to limit the
ability to identify the relevant device in the future;
- An advertising ID, such as the Apple IDFA or the Android Ad ID;
- IP address;
- Device manufacturer and model;
- The operating system and version running on Your system or device;
- Language;
- The make of the CPU, and the number of CPUs present;
- Amount of memory present;
- Current screen resolution;
- Operating system identifier.

3.3. Cookies
We use Cookies and similar tracking technologies to track the activity on Our Website and Products
so store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track
information and to improve and analyze Our services. The technologies We use may include:
• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your
browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept
Cookies, You may not be able to use some parts of our Service. Unless You have adjusted Your browser
setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files
known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Us, for
example, to count Users who have visited those pages or opened an email and for other related website
statistics (for example, recording the popularity of a certain section and verifying system and server
integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal
computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close
Your web browser. We use both Session and Persistent Cookies for the purposes set out below:
− Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website
and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use
of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and
We only use these Cookies to provide You with those services.
− Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
− Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow Us to remember choices You make when You use the Website, such
as remembering Your login details or language preference. The purpose of these Cookies is to provide You
with a more personal experience and to avoid You having to re-enter Your preferences every time You
use the Website.

4. How We Use Your Data
4.1. Processing Your Requests
We use Your Data to process Your request for contact and/or Products.
For example, to get Our Products or make contact with Us, You must provide Your name and e-mail.
4.2. Administering the Product and the Website
We also use Your Data for any lawful business purpose in connection with administering the Product
and the Website, including without limitation for customer service, to help diagnose problems with
servers and the Product or the Website.
4.3. Communications
We may use Your PII to communicate with You about new features, events, or other products
offered by Us.
4.4. Legal Requests
We and Third Party may also provide access to Your Data to cooperate with official investigations
or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials,
as well as private parties, including, for example, in response to subpoenas, search warrants, court orders,
or another legal process.
4.5. Transfer or Sale of Our Business or the Product
As our business changes, We may buy or sell various assets owned or controlled by Us. In the event
all or a portion of the assets are sold, assigned, transferred, or acquired by another company due to
merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or
otherwise, Your Data may be among the transferred assets.
4.6. Security and Investigations
We can use Your data (including Your communications) for security purposes or to prevent or
investigate possible fraud or other violations and/or attempts to harm our Members, Visitors or others.
4.7. Retention of Your PII
We will retain Your PII only for as long as is necessary for the purposes set out in this Privacy Policy.
We will retain and use Your PII to the extent necessary to comply with our legal obligations (for example,
if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our
legal agreements and policies.
We will also retain Data for internal analysis purposes. Usage Data is generally retained for a shorter
period of time, except when this data is used to strengthen the security or to improve the functionality of
Our Products or Website, or We are legally obligated to retain this data for longer time periods.
5. Sharing Your Data for Marketing; Opt-Out; How to Update Your Data
5.1. Credit/Debit Card and Payment Account Data.
We will not ask, and get, and sell, and share, and rent Your credit/debit card number or payment
account Data or any Your sensual data.
5.2. Sharing Your Data for Marketing
We will not share Your Data.
5.3. Links To Other Sites
Our Website and our Product may contain links to other sites, and apps that are not operated by
Us. If You click on a Third party’s link, You will be directed to that Third party’s site or app. We strongly
advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices
of any Third party’s sites or services, or applications.
5.4. Legal Disclosures
It is possible that We will need to disclose information about You when required by law, subpoena,
or other legal processes or if We have a good faith belief that disclosure is reasonably necessary to
1) investigate, prevent or take action regarding suspected or actual illegal activities or assist
government enforcement agencies;
2) enforce our agreements with You;
3) investigate and defend ourselves against any third-party claims or allegations;
4) protect the security or integrity of our Services (such as by sharing with companies facing similar
threats);
5) exercise or protect the rights and safety of our members, personnel or others.
We may dispute such demands when We believe, in our discretion, that the requests are overbroad,
vague, or lack proper authority, but We do not promise to challenge every demand.
6. Online Behavioral Advertising (OBA) and How to Opt-Out of OBA
6.1. How OBA Works
Third-Party Providers will at times also use Tracking Technologies for purposes of “online behavioral
advertising” (OBA). OBA allows the serving of advertisements tailored to interests You have shown by
browsing on the Product and other sites, applications, destinations, and services, using the same or a
different Device. To enable OBA, these Third-Party Providers use Tracking Technologies to collect Data
including for example the make, model, settings, specifications (e.g., CPU speed, connection speed,
browser type, operating system, device identifier), and geographic location of Your Device, as well as
date/time stamp, IP address, pages visited, time of visits, Content viewed, ads viewed, the site(s),
application(s), destination(s), and/or service(s) You arrived from, and other clickstream data. The use of
Tracking Technologies by Third-Party Providers is subject to their privacy policies, not this Privacy Policy,
and We have no responsibility or liability in connection therewith. You may visit Third-Party Providers'
sites and discover their privacy policies.
6.2. Opt-Out of OBA
If You do not want OBA at all, You may be able to opt-out by visiting http://www.aboutads.info,
http://www.networkadvertising.org, http://www.Youronlinechoices.com/uk аnd/or by clicking the “Ad
Choices” icon that appears in advertising served through OBA. Please note that the option to opt-out
applies only to tracking by Third-Party Providers across this Product and other sites, applications,
destinations, and services, and not tracking among pages within the Product itself.
7. Transfer of Your Data Among Jurisdictions
We are a Russia-based but our Product is geared to a worldwide audience. Your Data may be
processed, transferred to, and maintained on, servers and databases located in the Russian Federation.
8. Data Security and Notification
8.1. Security Measures
We take commercially reasonable security measures to protect against unauthorized access to, or
unauthorized alteration, disclosure or destruction Data that You share with Us.
8.2. No Liability for Breach
Because no data transmission is completely secure, and no system of physical or electronic security
is impenetrable, We cannot guarantee the security of the Data that You send to Us or the security of
servers, networks or databases, and by using the Product You agree to assume all risk in connection withYour Data. We are not responsible for any loss of such Data or the consequences thereof.
8.3. Breach Notification
If We believe the security of Your Data in our possession or control may have been compromised,
We may seek to notify You. If notification is appropriate, We may notify You by email, push notification,or otherwise.
9. Your Data protection rights under General Data Protection Regulation (GDPR)
9.1. If You are from the European Economic Area (EEA), our and Third parties' legal basis for
collecting and using the personal information described in this Privacy Policy depends on the PII We collect
and the specific context in which is collected.
Please note: We don't collect and process Your PII when You use the mobile application Univer
ONLINE.
Your Data may be collected on the following basics:
- Third parties need to perform an agreement with You;
- You have given a permission to collect and process Your Data;
- The processing is in our legitimate interests and it's not overridden by Your rights;
- To comply with the law.
9.2. If You are a resident of the European Economic Area (EEA), You have certain data protection
rights. If You wish to be informed what PII We hold about You, please contact Us. If You wish to be
informed what PII Third parties hold about You and if You want it to be removed from Third parties'
systems, please contact them.
9.3. In certain circumstances, You have the following data protection rights:
a) Your right of access
If You ask Us, We will confirm whether We are processing Your PII and, if so, provide You with a
copy of that PII (along with certain other details). If You require additional copies, We may charge a
reasonable fee for producing those additional copies.
b) Your right to rectification
If the PII We hold about You is inaccurate or incomplete, You are entitled to have it rectified. If We
have shared Your PII with others, We'll let them know about the rectification where possible. If You ask
Us, where possible and lawful to do so, We will also tell You who We've shared Your PII with so that You
can contact them.
c) Your right to erasure
You can ask Us to delete or remove Your PII in some circumstances, such as where We no longer
need it or where You withdraw Your consent (where applicable). If We have shared Your PII with others,
We will let them know about the erasure where possible. If You ask Us, where it is possible and lawful for Us to do so, We will also tell You who We have shared Your PII with so that You can contact them directly.
d) Your right to restrict processing
You can ask Us to "block" or suppress the processing of Your PII in certain circumstances such as
where You contest the accuracy of that PII or You object to Us processing it for a particular purpose. This may not mean that We will stop storing Your PII but, where We do keep it, We will tell You if We remove any restriction that We have placed on Your PII to stop Us processing it further. If We've shared Your PII
with others, We'll let them know about the restriction where it is possible for Us to do so. If You ask Us, where it is possible and lawful for Us to do so, We'll also tell You who We've shared Your PII with so that You can contact them directly.
f) Your right to data portability
You have the right, in certain circumstances, to obtain PII You have provided to Us (in a structured,
commonly used and machine-readable format) and to reuse it elsewhere or to ask Us to transfer it to Yourchosen third party.
e) Your right to object
You can ask Us to stop processing Your PII, and We will do so, if We are: (i) relying on our own or
someone else's legitimate interest to process Your PII, except if We can demonstrate compelling legal
grounds for the processing; or (ii) processing Your PII for direct marketing purposes.
g) Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it is based on automatic processing, including
profiling, if it produces a legal effect or similarly significantly affects You, unless such profiling is necessary for the entering into, or the performance of, a contract between You and Us.
h) Your right to withdraw consent
If We rely on Your consent (or explicit consent) as our legal basis for processing Your PII, You have
the right to withdraw that consent at any time. You can exercise Your right of withdrawal by contacting
Us using our contact details in the "How to Contact Us" section above or by using any other opt-out
mechanism We may provide, such as an unsubscribe link in an email.
i) Your right to lodge a complaint with the supervisory authority
If You have a concern about any aspect of our privacy practices, including the way We have handled
Your PII, please contact Us using the contact details provided in the “How to Contact Us” section below.
Please note that We may ask You to verify Your identity before responding to such requests.
10. Privacy Policy Coordinator
10.1. Our Privacy Policy Coordinator
If You have any concerns or questions about any aspect of this policy, please feel free to contact our
Privacy Policy Coordinator as follows:
Privacy Policy Coordinator – Ilia Astahov
e-mail: hello@stery.pro
If You wish to exercise this right, please contact our Privacy Policy Coordinator and state which of
these items You wish to opt-out of sharing with third parties.
Also, as discussed above, if You have registered on any part of the Product and You wish to update
or make changes to Your PII on file with Us, You may contact our Privacy Policy Coordinator.
10.2. Privacy Policy of Third Party
We use technologies provided by Google Inc. such as Google Play, so the Product contains elements
of code that allow the analysis of Data, research marketing indicators, payment processing, display of
mobile ads and the Product is distributed using the following Third parties:
a) Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043), conditions of processing
and protection of personal data of YANDEX LLC are located at the web address:
https://policies.google.com/privacy
b) YANDEX LLC (address: 16 Lev Tolstoy St., Moscow, Russia, 119021; TIN: 7736207543), conditions of processing and protection of personal data of YANDEX LLC are located at the web address: https://yandex.ru/legal/confidential
с) Individual entrepreneur Nikita Valentinovich Obukhov (TIN: 732808545705), conditions of
processing and protection of personal data are located at the web address: https://tilda.cc/ru/privacy.
You may opt-out of having Your data by these Third partis by contacting them.

Note: Only inquiries about this policy or Your PII should be sent to the Privacy Policy Coordinator.
No other communications will be accepted or responded to.
For communications on other matters, please contact Us through the means described on the
Product, if available (e.g. in the “Contact Us” section if it’s available).
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If You don't agree to the terms contained in this Privacy Policy, You must immediately exit the
Product and delete all Product's information from Device.